WASHINGTON DC REGIONAL HAZE SIP 

DDOE Response to FLM Comments 

US Department of Interior, National Park Service & Fish and Wildlife Service Comments 

(March 18, 2010) 

Figure 1.1. Include Class I areas in NH, VT and ME on the map as impacts at these Class I areas 

are discussed in subsequent sections. 

DDOE RESPONSE: DDOE has added a new map of all Class I areas in MANE-VU and 

VISTAS to Chapter 1 (see Figure 1.2). To more directly demonstrate Class I areas 

located near the District, the previous Figure 1.1 was replaced with a map that was 

initially in Chapter 9. 

Section 3.3.1, States Notifying the District of Contribution to Haze. The final paragraph of this 

section states that District’s contributions to MANE-VU and VISTAS Class I areas would be 

“...summarized below.” However, there is no contribution summary in Chapter 3. Please 

include in this section or highlight which chapter such a summary is available. 

DDOE RESPONSE: The contribution summary is located in Chapter 7. The document 

now refers to Chapter 7 instead of “below”. 

Section 4, Emissions Inventory. This section describes 2002 base year emissions and 2018 

future year emissions projects for the District and for MANE-VU states. These emissions data 

are used in MANE-VU air quality modeling (described in Section 6) to evaluate the District’s 

contribution to visibility impairment in nearby Class I areas. It is important that the assumptions 

used in these inventories are clearly defined 

DDOE RESPONSE: A paragraph was added to 4.1.1 to describe District-specific data 

sources used to develop MANE-VU’s 2002 base year inventory. Although control 

assumptions incorporated into the future year inventory scenarios are listed in Chapter 

10, they were added to 4.1.2. First, assumptions for the region are listed. Then, control 

factors that were applied for the District specifically are discussed.

Section 4.1.2 defines the MANE-VU “best and final” 2018 inventory as “developed to account 

for additional control measures considered as part of the development of the MANE-VU regional 

long-term strategy.” If this represents the emissions reductions that MANE-VU refers to as the 

“Ask”, please make that clear. It is important to define which of the additional control measures 

are being implemented as enforceable control measures and which are future goals that have not 

been enacted. Specifically, please clarify which of the control measures included in the 2018 

“best and final” MANE-VU inventory in Table 4.3 have been implemented in the District. 

DDOE RESPONSE: Emissions reductions represented in the “Ask” of other RPOs are 

included in Section 7.1. These requests are similar to the emissions reductions which 

represent MANE-VU’s reasonable progress goals (see Section 10.6.3): 

- Timely implementation of BART 

- Low-sulfur oil strategy 

- EGU strategy (167 stacks) 

- Other controls, including residential wood combustion 
These emissions reductions are the same as those reflected in the “best and final’ 

scenario. The region, including the District, and other RPOs have 10 years (by 2018) to 

pursue these strategies as reasonable and necessary. They are not necessarily enforceable 

yet. 

A statement was added to 4.1.2 to indicate that the “best and final” measures applied for 

the District (which are also part of the region’s reasonable progress goals) are future 

goals that have not been enacted. 

Section 4.3.1. Tables 4.1, 4.2, and 4.3: 

Please explain the basis for differences between the 2018 On the Books/On the Way inventory 

and the 2018 Final inventory for the District. What controls were assumed to reduce the 

District’s area source SO2 by 90% and non-EGU point source SO2 by 30% between the two 

2018 inventory versions? The document should specifically cite the emissions control measures 

taken by the District. If the emissions changes documented in Table 4.3 are illustrating potential 

emissions reductions rather than enacted control measures, this should be clearly described in the 

text. Please revise Tables 4.2 and 4.3 so that the order of presentation of emissions sectors is 

consistent, currently the order of area sources differs between the two tables. 

DDOE RESPONSE: Language was added to 4.3.1 and throughout Section 4 to address 

these concerns. The order of presentation of emissions sectors in the tables was made 

consistent. 

Please explain the basis for reductions in the MANE-VU regional 2018 emissions in Tables 4.6 

(2018 On the Books/On the Way) and 4.8 (2018 Final Emissions Inventory). Are these 

reductions the same as the MANE-VU “Ask”? Please explain if the emissions reduction 

measures included in these tables have been implemented. MANE-VU used the Final 2018 

inventory as the basis for air quality modeling to define visibility improvements by 2018. 

Therefore, it is important to understand the extent that reductions beyond On the Books/ On the 

Way will be implemented. 

DDOE RESPONSE: Language was added to 4.3.2 to address these concerns. 

Anthropogenic VOC emissions are only partially relevant to fine particulate mass because many 

of the anthropogenic volatile organic compounds do not react to form particles. It would be 

more helpful to report in Tables 4.1 to 4.9 primary organic carbon and primary elemental carbon 

emissions. Same comment for Figure 6.7. 

DDOE RESPONSE: The tables presented in the District’s SIP are a result of MANE-VU 

work. The District does not have the resources to revise the Tables 4.1 to 4.9 to include 

primary organic carbon and primary elemental carbon emissions information. 

The more pronounced impact of VOCs from the perspective of PM2.5 (to address haze), 

rather than hydrocarbons (to address ozone), is explained on pages 4-2 through 4-5 of the 

Contribution Assessment, along with a statement that, “we need further work to 

characterize the organic carbon contribution to regional haze in the Northeast and MidAtlantic states and to develop emissions inventories that will be of greater value for 

visibility planning purposes.” Language was added to Section 6.3.2 to emphasize the 

point. 
In Section 4.3.2 Emissions from the District Compared to MANE-VU Emissions 

The final statement of this section includes the conclusion that the District contributes 0.1% to 

0.3% of the SO2 emissions in the MANE-VU region. We recommend further language to 

explain why this conclusion is important to the overall consultation process and development of 

the District’s long-term strategy (i.e., linking the emission inventory results with the MANE-VU 

decision that consultation takes place among those states that contribute at least 2% SO2). 

DDOE RESPONSE: Language was added to Section 4.3.2 to address this comment. 

In Section 5.0 Air Monitoring Strategy, the District should include language that commits the 

District to continuing support of ongoing visibility monitoring in Class I areas. Currently, the 

IMPROVE network meets this monitoring goal. Support, in this context, means the District 

agrees IMPROVE is an appropriate monitoring network to track regional haze progress and that 

the District agrees to work with neighboring states and FLMs in meeting the goals of the 

IMPROVE program. 

DDOE RESPONSE: Language was added to Section 5.1 to address this comment. 

Section 5.1, the third paragraph describes the baseline visibility conditions at the 20 percent most 

impaired days and the 20 percent least impaired days for the baseline period 2000-2004. To 

define the pollutants contributing to visibility impairment, the District should include charts 

illustrating aerosol composition for IMPROVE monitors in Class I areas nearest the District 

(e.g., Shenandoah National Park, Dolly Sods Wilderness Area, Brigantine Wildlife Refuge) on 

the 20% worst and 20% best days in 2000-2004. These data can be found on the VIEWS 

website at: http://views.cira.colostate.edu/web/Composition/. 

DDOE RESPONSE: Section 5 is intended to introduce monitoring and modeling 

methods and protocols, not the results of monitoring or modeling. As mentioned in later 

in Section 5.1, “as a participant in MANE-VU, the District reviewed information about 

the chemical composition of baseline monitoring data at Class I areas in and near MANEVU in order to understand the sources of haze causing pollutants. Section 6 of this 

implementation plan summarizes this analysis.” 

Section 6.1 discusses which pollutants contribute most to visibility impairment, based on 

analysis that can be found in the Contribution Assessment (Appendix K, particularly in 

Section 3). The second paragraph states that, “In 2002, on the haziest 20 percent of days, 

sulfate accounted for one-half two-thirds of total fine particle mass and was responsible 

for about three-quarters of total light extinction at Class I sites...” Figure 6.1 portrays 

baseline results that compares sulfate to other contributors to haze on the 20 percent 

worst visibility days in seven Class I areas, including Brigantine, Shenandoah and Dolly 

Sods, which are all located near the District. The second paragraph also states that, 

“Even on the clearest 20 percent of days, sulfate typically constitutes 40 percent or more 

of total fine particulate mass in the region.” 

We believe this existing information is sufficient to define the pollutants contributing to 

visibility impairment. 

Section 5.2 is an abbreviated description of the air quality models that were used in the MANEVU visibility assessment. The SIP should include the model performance evaluations for these 
models to demonstrate that the models have appropriate skill for the intended application. At a 

minimum, the SIP should cite the specific location in the referenced documents where this 

information is provided. Because the District’s emissions are a very small fraction of total 

emissions in the MANE-VU region, these models are adequate to demonstrate the District’s 

relative contribution to visibility impairment, as described in Section 6. 

DDOE RESPONSE: Model performance evaluations from the Appendices are now more 

directly referenced throughout Section 5 (particularly in Section 5.2) of the SIP. 

 

In Section 7, we recommend including the June 7, 2007, statement that was approved by all 

MANE-VU member states. 

DDOE RESPONSE: The MANE-VU “Ask” of other RPOs was added to Section 7.1. 

The similar MANE-VU statement for states within MANE-VU is already included in 

Section 10.6.3. 

In Section 8, the District should state that that it supports the reasonable progress goals set by the 

Class I states, including those set by Virginia and West Virginia through the VISTAS process. 

DDOE RESPONSE: A statement has been added to section 8.1 to address this comment.

The Section 9, the BART determination is missing. The District’s Implementation Plan is not 

complete without the required BART analysis. Please provide an opportunity to review and 

comment on the draft BART determination as soon as practical. We will then review the BART 

analysis and submit follow-up comments as necessary. 

DDOE RESPONSE: The BART chapter (Section 9) was submitted to the FLMs for 

review on March 12, 2010. The FLMs concurred with the results and did not submit 

follow-up comments. 

Section 10, Long Term Strategy. Figure 10.2 is confusing because several of the Class I areas 

identified in the map are not in MANE-VU states. We recommend you delete this figure. The 

brief paragraph above the map correctly reports that impacts from wood smoke at MANE-VU 

Class I areas are likely due to emissions from MANEVU states. Were emissions strategies to 

reduce wood smoke considered? 

DDOE RESPONSE: The previous Figure 10.2 on wood smoke emissions has been 

deleted. All consideration of the wood smoke is now in Section 10.7.3. 

A common concern for SIPs submitted by the MANE-VU states is the modeling results that are 

used to evaluate progress are based on emissions assumptions for MRPO and VISTAS states that 

differ from the emissions assumptions made by those states. As a result, regional model 

projections for MRPO and VISTAS differ from projections made by MANE-VU. For example, 

VISTAS results projects Dolly Sods, WV will meet uniform rate of progress by 2018 while 

MANE-VU results which use different assumptions for the VISTAS states, projects that Dolly 

Sods will not meet uniform rate of progress. Section 10.9 cites VISTAS results for Dolly Sods, 

but MANE-VU results for Shenandoah. Please use the rate of progress results for Dolly Sods 

and Shenandoah that are used by WV and VA in their respective State Implementation Plans 

rather than the MANE-VU results for these sites. Or if you choose not to use these states’ 

results, please explain the basis for your decision. 
DDOE RESPONSE: Please refer to footnote 10 in section 10.8, which has been added to 

address this comment. At the time of submittal of the District’s implementation plan, 

Virginia’s final Regional Haze SIP was not available. This is why MANE-VU results are 

sited for Shenandoah in this SIP.

It is important to include in Section 10 the specific measures that the District has taken to 

implement the MANE-VU recommendations for emissions management. 

DDOE RESPONSE: The District has agreed to pursue MANE-VU recommendations as 

appropriate and necessary, as mentioned throughout Section 10.6 and summarized in 

Section 10.9. 

As part of the Reasonable Progress demonstration, the regional haze rule requires a four-factor 

analysis of potential emissions reduction options. The District should cite the MANE-VU Four 

Factor Report and define which of the source categories in the MANE-VU report are represented 

in the District’s inventory. The District should evaluate potential SO2 emissions reduction 

options for non-EGU point sources and area sources in the District, for instance low sulfur fuel 

oil. 

DDOE RESPONSE: MANE-VU’s four-factor analysis of additional reasonable 

emissions reduction strategies considered during development of the long-term strategy 

for all MANE-VU states is summarized in Section 10.6. There is no inventory 

documentation for this analysis, but the “best and final” emissions inventory results (see 

Section 4.2.7 and Section 10.9.1), which reflects MANE-VU’s final reasonable progress 

goals, does consider potential SO2 emissions reductions for non-EGU point sources and 

area sources in the District. Please refer to discussion related to Appendix I. 

We also recommend in order to satisfy the verification requirements of the regional haze rule, 

that the District commits to using the five-year review to look at where the District is in terms of 

emission projections. In the five-year review, if the District is not meeting projections, a SIP 

revision would be triggered allowing the FLMs and the public to review how the District plans 

on meeting projections. 

DDOE RESPONSE: The District commits to evaluating progress within five years of 

submittal of this initial plan in Section 2 of the SIP. Minimal clarification has been added 

to address this comment. 

It is critical for each MANE-VU member agency to commit to the goal of improving visibility. 

This includes the need to link all District programs together, such as regional haze planning and 

other District permitting programs, such as New Source Review (NSR) and Prevention of 

Significant Deterioration (PSD). For example, it is important to consider projected emission 

growth under NSR and PSD and how that may impact regional haze and reasonable progress 

goals. 

DDOE RESPONSE: Language has been added to Section 3.4.3 (#2 and subsequent 

paragraph) to clarify our understanding of this requirement to link all District programs 

together, such as regional haze planning and permitting. 
US Department of Agriculture, Forest Service Comments (March 20, 2010) 

The SIP lacks a 5-factor analysis of the potential emission control options for the BART 

determination. 

 DDOE Response: The BART chapter (Section 9) is now complete. 

The SIP lacks the actual BART determination based on the options of different sulfur contents 

for the fuel oil. 

DDOE Response: The BART chapter (Section 9) is now complete.

When discussing impacted Class I Wilderness areas, please include Otter Creek Class I 

Wilderness area. It is acceptable to discuss Dolly Sods and Otter Creek similarly since they are 

relatively close together, but as they are distinct Class I areas it is important to identify both 

areas. 

DDOE Response: The Otter Creek Wilderness area was not modeled in some of the 

MANE-VU exercises where Dolly Sods was modeled. This made it difficult to mention 

Otter Creek in some parts of the SIP. Where appropriate, the District has included 

references to Otter Creek. 

Please confirm that DC DEQ DOE is committed to following the MANE-VU modeling and 

recommendations included throughout the SIP. Most of the work is from MANE-VU, and the 

Forest Service would like to be sure that Washington DC supports that work and is committed to 

following through with the recommendations of the Regional Planning Organization. 

DDOE Response: Language has been added to section 3.1 to address this comment.